HomeMy WebLinkAboutINDIVIDUAL COMMENT EMAIL - 128929General Plan 2040 - Draft 1
Feedback & Revisions
By
October 31, 2019 fes.
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Perspective and Bias
Review of the General Plan draft 1 was done with the best interest of Hilo, Hawaii in mind
through the continued development and support of a private agriculture business with 1,000
acres in Wainaku owned by Mahilani Partners LLC dba Lavaloha Chocolate Farm. Lavaloha c '
Chocolate Farm grows cacao, processing it into 100% single origin chocolate in a certified
production kitchen on site and sells it to locals and visitors through its"plan approved"
agritourism operation. Lavaloha intends to promote and stabilize the island's tourism industry by
diversifying the depences on lava activity and Mauna Kea access through enhancing visitor
engagement with agriculture and farm-to-table experiences.
How to Use this Analysis
The revievent chapters are presented below, outlining the stated goals that align with Lavaloha
pg 1-2). Proposed revisions to POLICY and ACTION are in BEEN with aspects for removal
highlighted in RED(pg 3-11). Feedback, questions and comments are written in BLUE with
corresponding sections highlighted to match. The policies of greatest concern are within the
Land Use Planning section highlighted on pages 9-11. It is our sincere hope that the
revisions and comments presented below may help shape the General Plan draft 2 for fulfilling
the GP goals the betterment of Hawaii.
General Plan & Lavaloha GOALS :
Section 1: Natural Resource Planning (GP Draft 1 pg 15)
1. Hawai'i will integrate traditional knowledge and practice with progressive planning strategies to
maintain environmental quality at the highest standards, address a changing climate, protect natural
resources,and restore ecosystem health for the benefit of present and future generations:
a) The resources and environmental quality of our air, noise,geology,waterways,groundwater,
forests, native habitats and wildlife,and coastal areas are protected and enhanced.The integrity
of our ecosystem services is enhanced to foster the resilience of natural systems and to ensure
their preservation and sustainable use for future generations.
Comment:Lavaloha shares a common goal of restoring the ecosystem health of our privately owned
400 acre forest reserve sub-zoned conservation (though under state jurisdiction),mauka our 600 acre
Ag-20 zoned land,for present and future generations to access and appreciate.
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General Plan 2040 - Draft 1
Section 3: Economic & Opportunity Planning (GP Draft 1 pg 75)
3. Hawai'i's local economy is diverse, stable, innovative, and complements the Island's unique ecology,
community character,and cultural heritage.We strive for residents to be economically self-sufficient
while focusing to reduce import dependence.
a) Agriculture is a robust, diversified sector that emphasizes food security and includes a broad
range of agricultural-based businesses,and agricultural tourism.
b) Residents have physical and economic access to sufficient,safe, nutritious,and locally
produced food to meet their dietary needs and food preferences for an active and healthy life.
c) Residents have physical and economic access to adequate and affordable housing in various
types,sizes and price ranges that meets the needs of the population and provides equitable
opportunities for household flexibility and mobility.
d) The visitor industry thrives by exposing vests to authentic cultural representations and by
providing interactive experiences with the 'aina and Hawai'i's natural wonders,while
maintaining a high quality of life for residents.
Comment:The goals of this section align with the work and benefits Lavaloha provides to Hawaii.
Section 4: Community Placemaking (GP Draft 1 pg 89)
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4. Hawaii is a safe, healthy, and diverse community deeply connected to the 'aina,our historical roots,
and in sustaining our multicultural heritage for future generations.We are invested in enhancing public
spaces, natural and cultural assets,and our social systems.
c) Health is prioritized by providing access to a wide variety of options and facilities that
promote physical activity and healthy lifestyle choices for residents and visitors of all ages.
d) Responsible and reasonable public access for spiritual, religious,cultural, recreational,and
subsistence practices is assured and protected.
Comment:connected to the aina=agriculture, historical roots=sugarcane flumes on Lavaloha land
Section 5: Land Use Planning (GP Draft 1 pg 119)
5. Hawaii will strategically use progressive planning strategies to direct and manage growth and
development to protect natural resources, ensure the safety of residents and visitors,and enhance the
quality of life.The principle land use strategy for design and implementation will focus on achieving a
sense of place by protecting and enhancing community character through natural systems planning,
smart growth strategies,and compatible land use planning that incorporates culture and equity into the
planning and decision-making process.
Comment: Lavaloha shares these objectives through company development.
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General Plan 2040 - Draft 1
Reminder:
Proposed Revisions in GREEN
Edit Removals in RED
Feedback/Questions/Comments BLUE
Section 1: Natural Resource Planning
pg 15) PROTECTING NATIVE HABITATS &WILDLIFE SUSTAINABILITY OBJECTIVE... Increase native habitat
restoration on County owned or managed land and privately owned conservation land and resource
lands.
Comment:The General Plan should support county residents in efforts to restore and reforest
privately owned lands, including those in state jurisdiction that align with the Natural Resource
Planning goals to"enhanced to foster the resilience of natural systems and to ensure their
preservation and sustainable use for future generations. (pg 15)"
pg 23) MANAGING STREAMS AND WATERSHEDS SUSTAINABILITY OBJECTIVE Reduce
impaired inland and marine waters.
pg 24) POLICY:#52 :Support the DOH and DLNR in its effort to have an implemented conservation plan
for all agricultural operations and a nutrient management plan for application of all animal and chemical
nutrients,through engaging with agriculture land owners and prioritizing sustaining operations along
with sustaining natural resources.
Comment: Plans and policy that influence and dictate limitations on operations of agriculture land
without considering the various unique circumstances per farm, run the risk of harming the
practicality and sustainably of operations and GP food security goals(pg 78)if not taking into account
individual landowner capacity.
pg 24)ACTION:# 1.16 : Create incentives for landowners to retain and re-establish forest cover in
upland watershed areas,including state jurisdiction conservation land,with emphasis on native forest
species.
Comment:General Plan needs to help bridge the gap between county and state regulations,
supporting landowners with conservation land within"state jurisdiction"in support of fulfilling GP
goals of re-establishing native forest species and stabilizing streams and watersheds.
pg 28) POLICY:#67 : Require the consolidation of contiguous parcels that do not conform to current
code (non-conforming) in high risk hazard areas.
Comment/Question:When will"high risk areas"be determined and by who? How does requiring
consolidation benefit of mitigate risks?How will this impact privately owned agriculture lands and
their management?
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General Plan 2040 - Draft 1
Section 2: Infrastructure Planning
pg 57) POLICY: # 186 : Provisions for on-street parking shall be evaluated during the design of road
systems with review of previously established roads as necessary with possible revision of provisions
for on-street parking where hazard or restriction of efficient and comfortable movement of people
and goods may persist.
Comment:Some old roads were made prior to the increase in modern traffic flow and still allow for
on-street parking, requiring one directional flow of traffic at a time wherein cars have to pull over to
let the other pass:ie,county section of Amauulu Rd in Wainaku.Old roads need to be evaluated for
current capacity needs as well as new roads.
pg 57) POLICY:# 188 : Develop rural road standards to ensure appropriate levels of public safety.
Comment:Consider"grandfathered in"road development time framers wherein old cane/farm roads
are allotted a generous time frame and grant program support for meeting modern safety standards.
Section 3: Economic & Opportunity Planning
pg 76) POLICY:#279 : Promote sustainable business development opportunities focusing on diversified
agriculture, educational and institutional research-based tourism,green technologies and building, and
sustainable tourism.
Comment:YES! GP can support/implement this policy through revising restrictions on agritourism
operations,such as limit to visitor head count and limit to"covered 1,000sq ft area"for tourism
operations
pg 76) POLICY:#288 : Partner with business associations, realtors,and the chamber of commerce to
recruit small-scale manufacturers to establish retail locations in village, on agriculture land and town
centers to support reinvestment.
Comment: remove barriers for agriculture focused commercial retail operations on ag land to support
GP Economic Goals&therefore Ag Goals of sustainable operations supporting food security.
pg 77) POLICY:#291 : Maintain a program for updating zoning code to accommodate emerging
industries and technologies consistent with other goals,objectives and policies of this General Plan.
Comment:YES!Such as Agritourism industry which is necessary for financial feasibility of sustained
farming efforts and GP goals of food security and diversifying the tourism industry for Hawaii County.
pg 77) POLICY:#292 : Partner with business associations, realtors,and chamber of commerce to
remove regulatory barriers and create incentives for urban and agricultural renewal, rehabilitation,
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General Plan 2040 - Draft 1
and/or redevelopment programs in cooperation with communities, businesses,farms and governmental
agencies, instead of developing new commercial areas.
Comment:Excellent and strong verbiage should include/apply to agriculture land and farm support!
pg 77) POLICY:#294 : Partner with business associations, University of Hawai'i at Hilo, and other
agencies and private entities to host local fairs, markets, and networking events on agriculture land and
in target communities,removing permitting barriers.
Comment: Land use and special permit barriers impede this policy's goal of partnering for local fairs,
markets and networking events in alignment with supporting agriculture,food security and
diversifying tourism industry.
pg 77) POLICY:#296 : Remove regulatory barriers that restrict entrepreneurial endeavors,such as
zoning restrictions for home-based and farm-based businesses that do not negatively impact the
infrastructure network or the character of the neighborhood or farm.
Comment:YES!!! Remove regulatory barriers that restrict farm-based business!!
pg 77) POLICY:#298 : Encourage partnerships that leverage existing infrastructure and financial
resources as well as projects that provide for additional infrastructure resources desirable for
development of sustainable local industries.
Comment:YES!!!Support AGRITOURISM as sustainable local industry!
pg 77) POLICY:#297: Encourage land uses that allow for small-scale manufacturers and retail
establishments that enhance and are balanced with the County's agricultural,natural,cultural,and
social environments.
Comment:YES!Change"in"to"and"+add"agricultural"to the County's environments to
encouraged,enhanced and balanced land uses.
pg 78)AGENCY ACTION:#3.14: State:Appropriate and release funds for Capital Improvements in
visitor areas.
Comment:Establish ag land as incentivized visitor area and provide capital investment,such as road
infrastructure.
pg 79) POLICY:#299 : In order to provide a means for local agricultural producers to market their
products,the County shall interpret HRS 205 liberally to allow the establishment and continued
operations of open farmers' markets,ag-based retail operation gift shops and road-side stands in the
State Land Use Agricultural district without a Special Permit and with no limitation on covered space
square footage. If the project qualifies for Plan Approval,a market management plan containing
provisions for adequate on-site parking,on-site and off-site traffic management,and adequate
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General Plan 2040 - Draft 1
sanitation facilities must be approved by the Planning Department prior to the operation of the open
farmers market.
Comment: Hilo district rains frequently and needs to sustain visitor engagement and comfort
throughout the rainy seasons. It is important to allow farmers markets,roadside stands and ag-based
retail outlets to be carried out in covered spaces,so long as they fit within Plan Approval and don't
have an arbitrary limit of designated square footage usage for visitor engagement. Include repurposed
residential buildings for farmers market or retail operations,removing barriers and working with
private companies to achieve goals of diversifying the tourism industry.
pg 79) POLICY:#300 : Educate landowners about agriculture, ranch,and forestry land preservation
programs and encourage participation in these programs.
Comment: How?When?What metrics will ensure landowners are educated and have access to
beneficial programs?
pg 79) POLICY:#301 :Assist in the expansion and promotion of the agricultural industry through
agritourism and the protection of viable and productive agricultural lands.
Comment:Expand the policy to include supporting agritourism as vital revenue stream for
maintaining agricultural operations longevity.
pg 79) POLICY:#303 :Support the development and stability of marketing plans, programs,cooperative
groups,and other networking organizations that promote the agricultural industry.
Comment:AGRITOURISM...GP needs to explicitly support Agritourism as a way of achieving economic
goals through diversifying tourism industry and agriculture land use goals ensuring farmers can afford
to grow food supporting food security goals.
pg 79) POLICY:#304 :Support the development of private and state agricultural parks to make
agricultural land available for agricultural activities.
Comment: How are"agricultural parks"defined? NO CLEAR DEFINITION within county planning
department.There is mention of it as a permissible use of ag land in state law: HRS 205#11,however
no definition or parameters are provided.
pg 79) POLICY:#310 : Promote operations that utilize local materials and secondary byproducts from
agriculture,agroforestry,silviculture,and aquaculture to any degree without limitations on quantity of
local product or requiring it to be the primary ingredient,accommodating a diversity of business
operations and scale.
Comment:Refine restriction on sales of ag related products not requiring the primary ingredient to be
locally sourced,but allowing for a"majority of ingredients to be locally sourced"mindset.
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General Plan 2040 - Draft 1
pg 80)ACTION:#3.20 :Amend code to remove barriers to allow for off-site directional signage to
promote local farms engaged in direct sales and other permitted visitor-related businesses,while
minimizing scenic impacts. [Code]
Comment:YES!Thank you! Promote FARMS!
pg 82)SUSTAINABILITY OBJECTIVE: Increase availability of infrastructure(agricultural water,
transportation systems for product and equipment access, and packing and processing facilities for
ranching,agricultural crops,timber,and value-added products)to areas of high agricultural production.
Comment:YES!Support value-added agriculture processing.THANK YOU! How? Metrics?
pg 82) POLICY:#322 : Promote agricultural processing, including the development of non-profit or
private commercial kitchens, processing, storage, and distribution facilities including retail centers on ag
land, using existing facilities as appropriate for the development and sale of value-added local products.
Comment:YES!Support single-origin growth, processing and sale of value-added ag products!
pg 82) POLICY:#324 : Incentivize and remove barriers to allow the agricultural industry to provide or
develop employee housing and workers quarters.
Comment:YES'S""" We love when the GP"REMOVES BARRIERS"!!!
pg 83) DEVELOPING A PLACE-BASED VISITOR INDUSTRY SUSTAINABILITY
OBJECTIVE: Increase visitor expenditure or length of stay.
Comment:This is a Lavaloha goal too through enhancing awareness and engagement with the natural
beauty of Hawaii and local agriculture food appreciation.
pg 84) POLICY:#326 : Encourage,where appropriate,the establishment of visitor-related uses and
facilities that directly promote the agriculture industry.
Comment:YES!AGRITOURISM!!!Support single-origin growth,processing and sale of value-added ag
products ON AG LAND! Remove barriers for conducting agritourism,such as limits on covered space,
hours of operation and visitor headcount restrictions.
pg 84) POLICY:#327 :Support the promotion and development of programs,festivals, and events that
engage visitors and residents in unique and authentic ways.
Comment: Remove barriers and special permit requirements for conducting programs,festivals and
events on agriculture land which is a vital way to engage visitors in sustainable tourism while
supporting local agriculture through additional revenue streams.
pg 84) POLICY:#328 : Support the development of a place-based tourism industry that emphasizes the
preservation of our unique cultural, natural,and built environment assets.
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General Plan 2040 - Draft 1
Comment:YES! Place-based tourism industry of agriculture land!The identity of Hawaii's tourism
needs to be more sustainable than lava flow which may or may-not be active or accessible year round.
Agriculture is a sustainable tourism model of made accessible and also allows farms to continue to
afford to farm.
Section 5: Land Use Planning
pg 121)ACTION:#5.3 :Amend zoning code and administrative rules to add criteria for Plan Approval
requirements.
Comment: By adding criteria for Plan Approval Requirements,this action goes against the goals
stated in economic development section to"remove barriers". Refer to:"(pg 82)POLICY:#324.
Incentivize and remove barriers to allow the agricultural industry to provide or develop employee
housing and workers quarters."
pg 121)ACTION:#5.4 : Establish a program of continuing review of the Zoning Code in light of emerging
new industries and technologies and incorporate revisions to land use regulations as necessary.
Comment:YES!Agritourism is a vital emerging new industry that can provide a long-term stable
tourism sector not dependent on lava activity or Mauna Kea politics.The Zoning Code should remain
available for review and revisions in support of Agritourism as the industry demonstrates its value
within stabilizing tourism with"farm-to-table"experiences while supporting food security and land
use goals.
pg 138) POLICY:#561 : Farm labor housing projects shall be developed in a (REMOVE word:clustered)
manner that minimizes the use of Productive Agricultural lands and is consistent with the character of
surrounding land uses.
Comment:Refer to:"(pg 82)POLICY:#324. Incentivize and remove barriers to allow the agricultural
industry to provide or develop employee housing and workers quarters."Remove barriers and
incentivize housing development for farm workers/owners. Remove the word"clustered"as housing
accommodations on Agriculture land need to be at the discretion of the land owner accomodating the
needs of the employees while still honoring the policy's intention of ensuring productive Agriculture
land is not impeded by housing accommodations.
pg 138) POLICY:#557 : Development and construction in "Productive Agricultural" and "Pastoral"areas
shall be limited to agriculture, related economic infrastructure,agritourism and cottage industries,
renewable energy,open area recreational uses,and community facilities unless otherwise permitted by
law.
Comment:Add in"agritourism"within related economic infrastructure and cottage industries,
incorporating support for Agritourism within the GP.
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General Plan 2040 - Draft 1
pg 138) POLICY:#559 :A maximum developable area shall be established for lots designated as
Productive Agricultural Land. Maximum Developable Area (MDA): Means the total floor area in square
feet allowed under the approved land use.The floor area computation shall include:all floor areas
under roof,including first,second,and third story areas, decks, pools,saunas;garage or carport,and
other above ground structures.
a) For lots up to 14,000 square feet,the maximum developable area is 25 percent of total lot
area.
b) For lots over 14,000 square feet to one(1)acre,the maximum developable area is 3,500
square feet.
c) For lots larger than one(1)acre,the maximum developable area is 5,000 square feet.
Rationale:This policy is based on the maximum developable area used for single-family residence in the
State Land Use Conservation district.]
Comment:REMOVE#559 ENTIRELY.The GP should NOT add barriers to agriculture land use and
development as every farm and farming endeavour is unique to the area and entity managing it.
Policy 559 creates an arbitrary blockade for development necessary for sustaining private agriculture
ventures.Structures are needed for,nurseries to grow keiki crops, processing and packaging products,
housing/processing livestock,storing and repairing machinery,offices for administration,retail spaces
consistent with regulation,employee spaces for eating and meeting,bathrooms and appropriate
community and visitor spaces consistent with HRS 205-2(d)etc. Furthermore, how do second and
third stories impede effective land use intended for agriculture production?Only the first story with
blueprint taking up physical land would impact the land use,however necessary the structure is to the
farm's operations. For the policy rationale to be based on single-family residence parameters further
demonstrates the lack of knowledge regarding covered spaces necessary for agriculture land use
operations and sustainability.
pg 139) POLICY:#562 :Agricultural land uses consistent with HRS 205-2(d)shall be considered
permitted uses and do not require an agricultural-based commercial-operations certification or Plan
Approval or Special Permit.
Rationale: based on the intent to apply HRS 205-2(d)consistently and simplify regulatory barriers to
agricultural activities.]
Comment:YES!!! Excellent. By adding in the words"plan approval or special permit"to the list of
non-requirements this policy aligns with GP goals of removing barriers and supporting agriculture
operations through accessory and secondary revenue streams necessary to sustain operations. HRS
205-2(d)states, "Agricultural tourism conducted on a working farm, or a farming operation as defined in
section 165-2,for the enjoyment, education,or involvement of visitors; provided that the agricultural
tourism activity is accessory and secondary to the principal agricultural use and does not interfere with
surrounding farm operations;and provided further that this paragraph shall apply only to a county that
has adopted ordinances regulating agricultural tourism under section 205-5;"
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General Plan 2040 - Draft 1
pg 139) POLICY:#563 : Certified,incubator,or community kitchens in the Rural or Agricultural District
REMOVE:that are under 1,000 square feet and do not provide for on-site tours and/or on-premises
sales)shall be considered a permitted use (agricultural processing)to be treated the same as
agricultural processing minor.Any certified kitchen in the Rural or Agricultural District exceeding 1,000
square feet needs to apply for plan approval.
Rationale: Based on HRS 205-2(d)6;25-5-72(a)(2); 25-5-62 (a)(1);25-5-52(a)(2) &the agricultural
products processing definitions from HCC Section 25-1-5.]
Comment:The GP can support more operations by removing,"that are under 1,000 square feet and
do not provide for on-site tours and/or on-premises sales"stipulations that exclude businesses with
certified kitchens on agriculture land for value-added ag product processing that may or may not
allow farm tours and ag-based retail operations that do not enter or inhibit processing or production
in the certified kitchen.
pg 140)ACTION:#5.19 : Establish agricultural subdivision standards that:
a) lower barriers to the creation of viable farmsteads by reducing infrastructure requirements
and expenses;
b) ensure public safety with appropriate rural water systems and roads;and
c) mitigate against speculative development. (REMOVE point c)
Comment:Agree with this action on points a)&b)...remove point c)because it could be
misinterpreted and used to restrict agriculturally beneficial industry development over 20 years.
pg 140)ACTION:#5.23 :Amend the Zoning Code to require Plan Approval for commercial open area
recreational uses in the uses in the"Productive Agricultural Lands" and "Pastoral" designations. [Code]
Comment: Not ALL of the acres within"productive agricultural lands"are farmable,such as gullies,
gulches,rivers and ravines. Currently the zoning codes allows for: Campgrounds, parks,
playgrounds, tennis courts, swimming pools, and other similar open area recreational facilities,
where none of the recreational features are entirely enclosed in a building. The current zoning
allows farmers additional revenue generation through community and visitor enjoyment of
non-farmable land.Amending the code to require Plan Approval provides a BLOCK to a viable revenue
stream for agriculture land regarding tourism and community place making.
pg 140)ACTION:#5.25 : Evaluate the nine categories used for the agricultural-based commercial
operation certification evaluations and simplify the process allowing for customized interpretation per
agriculture businesses entity to ensure facilitation and compliance with HRS 205-2(d)(15)and the
success of local agriculture ventures.
Comment: No two farms are the same:size,geography,crops,pest management,goals,business
model etc all play a part in operations.The GP should support customized interpertation rather than
blanket regulations that may benefit some but harm other depending on specifics per farm.
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General Plan 2040 - Draft 1
Conclusion
Draft 1 of the General Plan serves as a thorough and strong foundation for structuring the
growth and development of Hawaii for the next twenty years. A big MAHALO to the Planning
Department team for their comprehensive efforts put forth in drafting the GP and engaging the
public for feedback and perspective through speak-outs and workshops. As a citizen of Hawaii
and CEO of an agriculture business with a goal to enhance our island as a place to grow quality
food and spend quality time, I am proud to be in community with the fine folks that dedicate their
lives to making this the phenomenal place it is to live today and in twenty years.
In short, Thank You for what You Do!
I can't wait to review DRAFT 2!
Mahalo,
11
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